HAR PARSAD GOYAL,DELHI vs. ITO WARD 44(1), DELHI

PDF · subscribers
ITA 2192/DEL/2026Status: DisposedITAT Delhi27 July 2026AY 2014-153 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 of the Act was issued beyond the permissible time limit. Consequently, the re-assessment proceedings were vitiated and set aside.

What were the facts?

The assessee's appeal was against an assessment order passed under Section 147 read with Section 144B of the Income Tax Act. The primary issue revolved around the validity of the notice issued under Section 148 of the Act.

What were the issues?

The key issue was whether the notice under Section 148 of the Income Tax Act was issued within the prescribed time limit. The validity of the subsequent re-assessment proceedings was also in question.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144B,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “B”: NEW DELHI

For Respondent: Shri Rajesh Kumar Dhanesta, Sr
Hearing: 16/07/2026Pronounced: 27/07/2026

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE MS MADHUMITA ROY, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA No.2192/Del/2026 (A.Y 2014-15) Har Prasad Goyal Vs. Income Tax Officer, M-5, Mahavir Bhawan, Ward 44(1), Civic Centre, Karampura Commercial Minto Road, New Delhi Complex, New Delhi (Appellant) (Respondent) PAN: ADLPG3571G Assessee by : Sh. Pranav Yadav, Adv Revenue by: Shri Rajesh Kumar Dhanesta, Sr. DR Date of Hearing 16/07/2026 Date of pronouncement 27/07/2026 O R D E R PER MADHUMITA ROY, J. M.: The instant appeal filed by the Assessee is directed against the

order dated 29.12.2025 passed by the Ld. Commissioner of Income-

tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter

referred to as the Ld. CIT(A)/NFAC] under Section 250 of the Income

Tax Act, 1961 (hereinafter referred to as ‘the Act’) arising out of the

Assessment Order dated 10.05.2023 passed by the Assessment Unit,

Income-tax Department (hereinafter referred to as ‘the ld. AO’) under

Section 147 read with Section 144B of of the Income Tax Act, 1961

('Act' for shot) for Assessment Year 2014-15.

2 ITA No. 2192/Del/2026 Har Parsad Goyal

2.

The Notice under Section 148 of the Act is found to be time

barred which ought to have been issued on 05.07.2022 after taking

into consideration 33 days kept in the hands of the Ld. A.O. for

issuing the said notice. However, the same was issued on 27.07.2022.

The Notice under Section 148 of the act is found to be admittedly time

barred and, therefore, liable to be quashed, fact of which has not been

able to be controverted by the Ld. DR. Hence under the facts and

circumstances of the case, the Notice under Section 148 of the Act is

found to be barred by limitation and the same is is quashed.

Consequently, re-assessment proceeding is admittedly vitiated, void-

ab initio and thus, set aside.

3.

In the result, appeal filed by the Assessee is allowed.

Order pronounced in the open court on 27/07/2026. Sd/- Sd/- (RENU JAUHRI) (MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 27/07/2026 R. Naheed, Sr PS Copy forwarded to 1. Applicant 2. Respondent 3. CIT 4. CIT (A) 5. DR:ITAT ASSISTANT REGISTRAR ITAT, New Delhi

3 ITA No. 2192/Del/2026 Har Parsad Goyal

More judgments on Section 148

All 35,022 judgments and leading authorities on Section 148 →

Recent GST High Court judgments

Search GST case law →